ViaSat Ex Parte Subm

SUPPLEMENT submitted by ViaSat, Inc.

Supplemental Submission

2013-01-24

This document pretains to SES-LIC-20120427-00404 for License on a Satellite Earth Station filing.

IBFS_SESLIC2012042700404_982449

555 Eleventh Street, N.W., Suite 1000 Washington, D.C. 20004-1304 Tel: +1.202.637.2200 Fax: +1.202.637.2201 www.lw.com FIRM / AFFILIATE OFFICES Abu Dhabi Moscow Barcelona Munich Beijing New Jersey Boston New York Brussels Orange County January 24, 2013 Chicago Paris Doha Riyadh Dubai Rome Frankfurt San Diego VIA ELECTRONIC FILING Hamburg San Francisco Hong Kong Shanghai Ms. Marlene H. Dortch Houston Silicon Valley London Singapore Secretary Los Angeles Tokyo Federal Communications Commission Madrid Washington, D.C. 445 Twelfth Street, S.W. Milan Washington, D.C. 20554 Re: Ex Parte Submission of Supplemental Information; IBFS File Nos. SES- LIC-20120427-00404; SES-STA-20120815-00751, Call Sign E120075 Dear Ms. Dortch: ViaSat, Inc. submits information to supplement the above-referenced applications seeking authority to operate a Ka band aeronautical earth station (“AES”) network (“Applications”). Coordination Letters In order to expedite the processing of its Applications, enclosed as Exhibit 1 are copies of letters from satellite operators evidencing that the operation of this ViaSat AES network successfully has been coordinated with all potentially affected satellite networks: O3b’s NGSO Ka band network, and the Ka band GSO networks of Hughes Network Systems, SES, DIRECTV, Intelsat, EchoStar, Dish, Telesat, and Bell Canada.1 Thus, ViaSat has coordinated its proposed operations with all Ka band satellite networks that operate (or are expected within the next few years to operate) on a co-frequency and co-coverage basis with ViaSat’s satellite points of communication (i.e., ViaSat-1 at 115.1º W.L.; WildBlue-1 and Anik-F2 at 111.1º W.L.), and are located within +/-30º of those points of communication. Data Logging Capabilities ViaSat currently intends to log and maintain records of the following data for AES transmissions: aircraft location (latitude, longitude, altitude); aircraft velocity; aircraft attitude 1 Bell Canada indicates that it is authorized to operate a Ka band satellite network at 82º W.L. DC\2376416.3

Ms. Marlene H. Dortch January 24, 2013 Page 2 (pitch, yaw, roll); transmit channel group;2 EIRP density; and satellite used for the communication. The logged data also would include any instances when the AES terminal pointing error exceeds the inhibit limits (0.5 degrees azimuth and 1.35 degrees elevation, or 60 degree combined bank and skew). These data will be more than adequate to ensure that any concerns about the source of suspected interference into other spacecraft can be ascertained (and then addressed). As to the timing interval of logging, the Commission has adopted rules requiring Ku band AES licensees to collect data at one minute time intervals and maintain that data for “rolling” one-year periods.3 The Commission already has determined that logging AES data at one- minute intervals is more than adequate to ascertain the location of an aircraft and identify a particular terminal as the source of an RF transmission that is suspected to be a source of interference.4 This is true regardless of the transmit frequencies used. Off-Axis EIRP Density Plots ViaSat’s October 15, 2012 notice of ex parte presentation (“October 15th Ex Parte Notice”) included plots illustrating the AES antenna transmit performance. Specifically, the plots depict the areas where the EIRP emitted by the grating lobes of the antenna potentially could exceed the Section 25.138 spectral power density mask (under certain operating conditions). Enclosed as Exhibit 2 is a revised version of one of those plots that includes a legend and additional clarifying notations. 2 As described in ViaSat’s December 17, 2012 ex parte submission, the SurfBeam 2 architecture uses MF-TDMA and can change transmit frequency and symbol rate every 40 ms within a given 62 MHz wide grouping of channels. The channel bandwidth of a given transmission can be determined by knowing the EIRP density of the transmission and the identified frequency range within which the transmission occurred. 3 Revisions to Parts 2 and 25 of the Commission’s Rules to Govern the Use of Earth Stations Aboard Aircraft Communicating with Fixed-Satellite Service Geostationary- Orbit Space Stations Operating in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz and 14.0-14.5 GHz Frequency Bands, IB Docket No. 12-376, Notice of Proposed Rulemaking and Report and Order, FCC 12-161 ¶ 89 (rel. Dec. 28, 2012) (“ESAA Order”). 4 ESAA Order at ¶ 89 (“Given the rapid rate at which motion and direction could change within the ESAA systems, ESAA licensees will be required to collect this data on one minute time intervals.”). Prior to the ESAA Order, the Commission typically required Ku band AES licensees to record data both (i) at intervals of two minutes under normal flight conditions, and also (ii) at intervals of 30 seconds when aircraft roll angle is greater than 10 degrees during the first year of operation. See Row 44, Inc., 24 FCC Rcd 10223 ¶ 35 (2009); see also Panasonic Avionics Corporation, 26 FCC Rcd 12557 ¶ 26 (2011). DC\2376416.3

Ms. Marlene H. Dortch January 24, 2013 Page 3 In addition, enclosed as Exhibit 3 is a copy of the map included in the October 15th Ex Parte Notice revised to include a legend for the contours illustrated on that map. The contours denote the geographic areas where the operation of an AES whose emissions at the grating lobes that exceed the Section 25.138 mask (under worst case operating conditions) theoretically could affect a particular GSO satellite at this specific location (77° W.L.). The different colored contours represent the potential effect quantified as a ΔT/T level. As depicted on that map, the resulting ΔT/T in this case would not be expected to exceed 0.5% because the operating areas where the AES transmissions would have to originate to produce a greater ΔT/T level are entirely outside of the coverage areas of the spacecraft that would serve this AES network (i.e., the identified areas over the Pacific Ocean and Canada are outside the service area of ViaSat-1, WildBlue-1 and Anik-F2). * * * * * * * Please contact the undersigned if you have any questions regarding this submission. Respectfully yours, /s/ John P. Janka Elizabeth R. Park Enclosures (Exhibits 1, 2, 3) cc: Robert Nelson Andrea Kelly Stephen Duall William Bell Howard Griboff Paul Blais Joseph Hill Byung K. Yi Alyssa Roberts Kathyrn Medley Kal Krautkramer Cindy Spiers Hsing Liu David Keir, Counsel to Row 44, Inc. DC\2376416.3

Exhibit 1


October 12, 2012 Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Attn: International Bureau Re: Engineering Certification of DIRECTV This letter certifies that DIRECTV is aware that ViaSat, Inc. (“ViaSat”) is seeking authority from the Commission to operate up to 4,000 technically identical transmit/receive earth stations mounted on aircraft using the 28.35-29.1 GHz and 29.5-30.0 GHz bands for uplink transmissions and the 18.3-19.3 GHz and 19.7-20.2 GHz bands for downlink transmissions. These earth stations will communicate with ViaSat-1 at 115.1º W.L., WildBlue-1 at 111.1º W.L., and ANIK-F2 at 111.1º W.L., pursuant to the technical parameters described in ViaSat’s application, IBFS File No. SES-LIC-20120427-00404, Call Sign E120075 (“ViaSat Application”). ViaSat has also requested special temporary authority (“STA”) to operate five such aeronautical earth station (“AES”) terminals pending the grant of the ViaSat Application. See IBFS File No. SES- STA-20120815-00751 (“STA Request”). DIRECTV is authorized to operate the Ka-band satellites listed in the table ybelow in all or parts of the satellite uplink bands 28.35-28.6 GHz and 29.25-30.0 GHz and the satellite downlink bands of 18.3-18.8 GHz and 19.7-20.2 GHz . DIRECTV is familiar with the technical and operating parameters of the proposed AES terminals described in the ViaSat Application and the STA Request. DIRECTV confirms that the operations proposed in the ViaSat Application and the STA Request are not expected to cause unacceptable interference into the operations of the networks listed in the table below.

List of DIRECTV Ka-band satellites Satellite Name Nominal Location (°W) SPACEWAY 1 103 SPACEWAY 2 99 DIRECTV 8 101 DIRECTV 9S 101 DIRECTV 10 103 DIRECTV 11 99 DIRECTV 12 103 Respectfully, Jack Wengryniuk Sr. Director, Spectrum Management and Regulatory Affairs DIRECTV




October 8, 2012 Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Attn: International Bureau Re: Engineering Certification from Intelsat This letter certifies that Intelsat is aware that ViaSat, Inc. (“ViaSat”) is seeking authority from the Commission to operate up to 4,000 technically identical transmit/receive earth stations mounted on aircraft using the 28.35-29.1 GHz and 29.5-30.0 GHz bands for uplink communications and the 18.3-19.3 GHz and 19.7-20.2 GHz bands for downlink communications, with Ka band satellites, ViaSat-1 at 115.1º W.L., WildBlue-1 at 111.1º W.L., and ANIK-F2 at 111.1º W.L., and pursuant to the technical parameters described in ViaSat’s application, IBFS File No. SES-LIC-20120427-00404, Call Sign E120075 (“ViaSat Application”). ViaSat has also requested special temporary authority (“STA”) to operate five such aeronautical earth station (“AES”) terminals pending the grant of the ViaSat Application. See IBFS File No. SES-STA- 20120815-00751 (“STA Request”). Intelsat is authorized to operate and currently operates the Galaxy 28 satellite at the 89º W.L. orbital location. Intelsat is familiar with the technical and operating parameters of the proposed AES terminals described in the ViaSat Application and the STA Request. Intelsat confirms that the operations proposed in the ViaSat Application and the STA Request have been coordinated with the Galaxy 28 satellite at the 89º W.L. and should not cause unacceptable interference into the operations of this satellite network. Respectfully, Jose Albuquerque Senior Director, Spectrum Strategy Intelsat




Telesat 1601 Telesat Court EN2012-003 Ottawa, ON, Canada 18 December 2012 K1B5P4 Via email Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Attn: International Bureau Re: Engineering Certification of Telesat This letter certifies that Telesat is aware that ViaSat, Inc. ("ViaSat") is seeking authority from the Commission to operate up to 4,000 technically identical transmit/receive earth stations mounted on aircraft using the 28.35-29.1 GHz and 29.5-30.0 GHz bands for uplink communications and the 18.3-19.3 GHz and 19.7-20.2 GHz bands for downlink communications, with Kaband satellites, ViaSat-1 at 115.1° W.L., WildBlue-1 at 111.1° W.L., and ANIK-F2 at 111.1°W.L., and pursuant to the technical parameters described in ViaSat's application, IBFS File No. SES-LIC-20120427-00404, Call SignE120075 ("ViaSat Application"). ViaSat has also requested special temporary authority ("STA") to operate five such aeronautical earth station ("AES") terminals pending the grant of the ViaSat Application. See IBFS File No. SES-STA-20120815-00751 ("STA Request"). Telesat is authorized to operate Ka-band satellites at the 118.7° W.L., 111.1°W.L., and 91° W.L. orbital locations. Telesat confirms that the ViaSat operations have been coordinated with the Telesat satellite networks and are not expected to cause unacceptable interference into the operations of the Telesat networks. Respectfully, Elisabeth Neasmith, P. Eng Manager ITU and Coordination Office of CTO Telesat Tel: 613-748-8700 • Fax:613-748-8712 • Information: http://www.telesat.com

Exhibit 2


Exhibit 3



Document Created: 2013-01-24 10:29:53
Document Modified: 2013-01-24 10:29:53
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